This Tower Cranes UK Limited (TCUK) Slavery and Human Trafficking Statement (Statement) is made pursuant to the Modern Slavery Act 2015 and relates to the financial year 01/04/2017 to 31/03/2018. This Statement covers the activities of TCUK. It sets out the steps TCUK  has taken prior to, or will take during, the Financial Year to ensure that slavery and human trafficking is not taking place in either any of TCUK ’s supply chains or in any part of TCUK ‘s business.

TCUK’s organizational structure, business and supply chains

TCUK is a privately owned company who has built a reputation as one of the premier ground works and RC concrete frame contractors in London and the home counties of England. TCUK supply chain is primarily comprised of organizations within the UK or Europe. TCUK Activities are primarily undertaken in the United Kingdom. TCUK UK does not normally operate directly outside UK.

TCUK’s Policy in relation to slavery and human trafficking

TCUK does not permit, condone or otherwise accept any form of slavery and/or human trafficking (as defined in the Modern Slavery Act 2015) either by its employees, subcontractors, contractors, agents, partners or any other organization, entity, body, business or individual with whom TCUK engages or does business. TCUK is committed to preventing any form of slavery and/or human trafficking in its activities and to ensure that its Associated Parties are free from any form of slavery and/or human trafficking. In the event that TCUK suspects any slavery and human trafficking by an Associated Party, TCUK reserves the right to: report such suspicions, provide appropriate information to the relevant authorities, and to suspend or terminate any associated engagement, business arrangement or contract. Each Associated Party is required to: put in place suitable management policies / system(s) for ensuring compliance with the Policy; extend the principles set out in this Policy to those engaged or acting on the Associated Party’s behalf, including contractors; and to permit TCUK to audit its compliance with the Policy, including making records available to TCUK to demonstrate compliance with the Policy.

TCUK’s due diligence processes in relation to slavery and human trafficking in its business and supply chains

To ensure that no slavery or human trafficking is taking place within its supply chain, TCUK shall;

  • Incorporate the Policy into TCUK’s Business Conduct Principles for suppliers, subcontractors and partners.
  • Publish the Policy on the TCUK internal staff portal & website for public access.
  • Publish the Business Conduct Principles on the TCUK website for reference.
  • Incorporate the Business Conduct Principles and thereby the Policy into the TCUK Purchasing Terms.
  • Include an acceptance condition in the TCUK supplier pre-approval questionnaire that suppliers will abide by the Policy.

The Parts of TCUK business at Risk

There may be a risk of slavery and/or human trafficking through organizations with whom TCUK contracts for the supply of products or services, or through organizations with whom TCUK subcontracts work to or partners with. The appointment of suppliers and subcontractors is subject to careful due diligence to ensure that there is no perceivable risk of slavery and/or human trafficking. TCUK engages only with reputable suppliers or parties that do not engage in any form of slavery and/or human trafficking. All such parties are also expected to adhere to TCUK Business Conduct Principles, which is incorporated into the process for being appointed as such and/or the relevant contractual relationship.  TCUK avoids contracting with suppliers or subcontractors which are located within geographical areas where slavery and/or human trafficking are a risk. In the event that TCUK contracts with Suppliers or subcontractors outside of the United Kingdom, it shall assess the supplier/subcontractor and the relevant geographic area on a case by case basis, undertaking any necessary due diligence in accordance with the paragraph below.  The TCUK Management shall be responsible for any compliance matters set out in this Statement and Policy, for ensuring due diligence and for undertaking audits. The TCUK HR Team is responsible for ownership of this Statement and Policy, including ensuring that it is up-to-date.

TCUK’s Effectiveness & Measures

The effectiveness of ensuring that slavery and human trafficking is not taking place in TCUK’s business or supply chains shall be assessed by application of the following key performance indicators;

  • To raise awareness of slavery and human trafficking by bringing the contents of the Statement and Policy to the attention of all staff, by publishing it under Company Policies on the internal portal and providing a formal notice to it. (Date required: within 28 days of Statement / Policy adoption, and in any event no later than 01 April 2016.)
  • Require staff that induct new employees to introduce employees to the Statement and Policy. (Date required: ongoing throughout the year.)
  • Incorporate supplier adherence to the TCUK Policy and the Business Conduct Principles within TCUK’s supplier appointment process. (Date required: within 28 days of Statement / Policy adoption, and in any event no later than 01 April 2016.)
  • Review all existing supply chains. (Date required: within 3 months of Statement / Policy adoption, and in any event no later than 01 June 2016.)

TCUK can provide awareness training about anti slavery and human trafficking to its staff

  • Visibility of the statement and policy on internal staff portal.
  • Communication to staff to read the Statement and Policy.
  • Annual reminder to ensure that staff is familiar with the Statement and Policy.
  • New staff to be introduced to slavery and human trafficking policy as part of their induction.

This statement has been approved by the TCUK board of directors.

 

Mr Trevor Diviney

Position: Managing Director             

Date: 1 st April 2018

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